The Federal Deposit Insurance Corporation (FDIC) recently announced (FIL-41-2012) a revision to the classification system for citing violations identified during compliance examinations. The revisions better communicate the severity of violations and help distinguish more serious violations from those more technical in nature. Violations are assigned to one of three classifications based primarily on the impact on the consumer. The three levels are: Level 3/High Severity – includes violations that may result in restitution to consumers […]
Tag: Lending Compliance
Compliance Masters Group Preview Session
Are you looking for help to keep up with all the regulatory changes? Compliance Resource, LLC is offering a free preview session of their Compliance Masters Group (CMG) this Friday, September 28th from 11-12pm EDT. During the one hour preview session you will be shown what a typical CMG session is all about. CMG members receive policies, procedures, director/ senior management updates, and much more. If you are interested in attending please email Amy Faust at amy@mycomplianceresource.com. Amy […]
MORE ON TESTING INTEGRATED MORTGAGE LOAN DISCLOSURES
Following our recent article about testing the integrated mortgage disclosure forms we received several inquiries requesting more information about the process, particularly about submitting a comment. This article responds to those requests. The Issue – The volume of changes from the Dodd-Frank Act that are currently unfolding is daunting. Over 2,400 pages of proposed regulations have been published in just the past two months alone. A huge bank can assign a team to the task of […]
YOUR ASSIGNMENT: TEST INTEGRATED MORTGAGE LOAN DISCLOSURES
The volume of changes from the Dodd-Frank Act that are currently unfolding is daunting. Based on the numerous complaints about the GFE and the HUD-1 I have fielded over the past 30 months, the issue of greatest concern may be the new integrated mortgage loan disclosures. The proposed rule for the Loan Estimate and Closing Disclosure covers 1,099 pages. Reading the proposal, gaining an understanding of the requirements, and trying your hand at completing the […]
INTERAGENCY PROPOSAL FOR APPRAISALS FOR HIGHER-RISK MORTGAGES
On August 15, 2012 the Federal Reserve Board, the Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively, the Agencies) jointly proposed to amend Regulation Z, to implement a Dodd-Frank Act provision requiring appraisals for “higher-risk mortgages.” Comments are due on or before October 15, 2012. The 211-page proposed rule generally defines a “higher-risk mortgage” as a closed-end consumer […]